Supreme Court Directs Ecological Restoration of Corbett and Permits Regulated Tiger Safaris Only in Non‑forest or Degraded Buffer Areas

A bench of Chief Justice B.R. Gavai and Justices Augustine George Masih and A.S. Chandurkar heard applications arising from the long‑running IN RE: Corbett proceedings (Writ Petition (C) No. 202 of 1995) concerning illegal constructions, felling of trees and the regulatory regime for Tiger Safaris in Corbett Tiger Reserve. The Court considered the Expert Committee report constituted pursuant to its earlier judgment dated 6 March 2024 and the status of the CBI probe and departmental proceedings.

The Court summarised its principal directions and clarifications. It accepted the Expert Committee’s recommendations for in‑situ ecological restoration of areas affected by works related to the Pakhrau Tiger Safari, directed demolition and restoration under CEC supervision, and required States to notify and regulate Eco‑Sensitive Zones (ESZs) and Tiger Conservation Plans (TCPs). The Court held that “Tiger Safari shall not be permitted in the core or a critical tiger habitat area” and that any Tiger Safari may be allowed only on non‑forest or degraded forest land in the buffer that did not form part of tiger corridors, and only in conjunction with a fully operational rescue and rehabilitation centre. The Court ordered that the entire area of a Tiger Reserve (including its ESZ) be notified as a “Silence Zone” under the Noise Pollution (Regulation and Control) Rules, 2000 and imposed a complete ban on night tourism in core areas.

The Court, in its reasoning, observed:

The judgment set out quantified estimates furnished by the Expert Committee for restoration and ecological loss — approximately Rs. 4.30 crore for in‑situ restoration and a further assessed ecological loss of around Rs. 22.95 crore (with net timber value of Rs. 6.8 crore), aggregating to about Rs. 29.8 crore — but directed that restoration proceed under CEC supervision without adjudicating valuation pending criminal and disciplinary processes. The Court also reiterated the factors it had earlier prescribed for any Tiger Safari: the approach must be “of ecocentrism and not of anthropocentrism”, the precautionary principle must apply, animals must not be sourced from outside the reserve (only injured, conflicted or orphaned animals may be exhibited), and safaris should be proximate to rescue centres.

Background

The proceedings arose from an application by Gaurav Kumar Bansal and subsequent public interest litigation concerning unauthorised construction, large‑scale tree felling and establishment of a Tiger Safari at Pakhrau within Corbett Tiger Reserve. In its March 2024 judgment, the Court had allowed existing Safaris to continue subject to stricter standards and had directed constitution of an Expert Committee to examine restoration, governance and operational protocols and to identify officers potentially liable for damage. The MoEF&CC constituted the Committee in March 2024, which conducted field visits, consulted experts (including IIFM), and submitted recommendations on Corbett and general pan‑India measures for tiger reserves.

While the CBI completed investigation and filed a chargesheet against several forest officials, and the State of Uttarakhand initiated departmental proceedings, the Expert Committee recommended demolition of unauthorised structures, hydrological repairs, native species afforestation, development of carrying‑capacity norms, CZA approval for enclosures, promotion of electric/solar vehicles, zero wastewater discharge, and expanded institutional and funding reforms. The Court directed the State (through Chief Wildlife Warden) to submit a restoration plan within two months, begin demolition within three months, and file a compliance affidavit within one year. It also directed all States to notify core and buffer areas, prepare or update TCPs and ESZs within specified timeframes, and implement wide‑ranging human‑resource, funding, conflict‑management and infrastructure measures recommended by the Committee. The Court kept the proceedings pending to monitor compliance and to enable recovery of restoration costs from delinquent officers after completion of disciplinary processes.

Case No.: I.A. No. 20650 of 2023; I.A. No. 75033 of 2023; I.A. No. 199355 of 2024 in Writ Petition (C) No. 202 of 1995 (IN RE : CORBETT) Case Title: IN RE : CORBETT (T. N. Godavarman Thirumulpad v. Union of India & Others) Appearances: For the Petitioner(s): Mr. Gaurav Kumar Bansal (applicant in person) For the Respondent(s): Ms. Aishwarya Bhati, Additional Solicitor General of India; Shri Abhishek Attrey, Standing Counsel for State of Uttarakhand; Mr. K. Parameshwar (Amicus Curiae assisting the Court)